INTERNAL AUDIT REPORT 
Operational Audit 
South King County Community Impact Fund 

January 2021 – June 2022 


Issue Date: November 23, 2022 
Report No. 2022-12

          South King County Community Impact Fund 

TABLE OF CONTENTS 

Executive Summary ................................................................................................................................................. 3 
Background ............................................................................................................................................................. 4 
Audit Scope and Methodology ............................................................................................................................... 5 
Schedule of Findings and Recommendations ....................................................................................................... 6 
Appendix A: Risk Ratings ......................................................................................................................................... 8 
Appendix B: Contract Values and Reimbursements .............................................................................................. 9 
Appendix C: Exceptions ........................................................................................................................................ 10 
Appendix D: Contract Example ............................................................................................................................ 11 












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          South King County Community Impact Fund
Executive Summary 
Internal Audit (IA) completed an audit of the South King County Community Impact Fund (SKCCIF). The
audit covered an 18-month period beginning January 2021 and was performed to determine whether
internal controls were in place and followed, and to validate if reimbursements complied with contract
requirements. Applying an “Equity Lens,” we considered modifications to the program to lessen the
burden on the community organizations that depend on this funding. 
In 2017, the Port of Seattle (Port) established the Airport Community Ecology Fund, allocating $1 million
of environmental benefits to airport communities who were impacted by airport noise and pollution. In
2019, the Port established the South King County Fund (SKCF) and pledged $10 million in funding over
a five-year period. The objective of the SKCF was to provide environmental benefits to near airport
communities impacted by airport noise. In November 2021, the name was changed to the South King
County Community Impact Fund (SKCCIF) with the goal of developing equity-based partnerships, and
to provide resources and support in historically underserved, ethnically, and culturally diverse nearairport
communities. 
The Economic Recovery Program is governed by Revised Code of Washington (RCW) 53.08.245
Economic development programs authorized - Job training and education. Bookdha Gheisar, Senior
Director, Equity, Diversity, and Inclusion, is the Port’s Executive Sponsor. For the 18-month period
ending June 30, 2022, approximately $872,000 had been paid under this program. 
The Environmental Program is governed by RCW 35.21.278 Contracts with community service
organizations for public improvement. The Port’s Executive Sponsor is Pearse Edwards, Senior Director
of External Relations. Approximately $68,000 had been reimbursed under this program, for the 18-month
period.
Both programs support the Port’s mission of promoting economic opportunities and quality of life in the
region by advancing job creation in an equitable, accountable, and environmentally responsible manner. 
We concluded that although internal controls should be improved, refinements to contract requirements 
would allow for more flexibility. This most likely will result in gained efficiencies, by requiring less time 
from internal staff and external stakeholders to adhere to contract requirements. These efficiencies
would allow Port staff to build stakeholder relationships, to perform oversight from site visits, and to
partner with community organizations. This issue is provided below and discussed in more detail
beginning on page six.
(Medium) – Approvals were not always documented, expense reimbursements were not always
supported with receipts, and expenses sometimes exceeded thresholds allowable by the contract.
Although the financial impact is relatively small, these exceptions could be considered non-compliance
with contract terms. 

Glenn Fernandes, CPA 
Director, Internal Audit 
Responsible Management Team 
Pearse Edwards, Senior Director, External Relations 
Bookda Gheisar, Senior Director, Equity, Diversity and Inclusion 

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          South King County Community Impact Fund
Background 
The South King County Community Impact Fund (SKCCIF) was established by a collective effort from
multiple Port stakeholders. Port Commission approved Motion 2019-10, on June 25, 2019, which 
included eight guiding fund principles. The Motion also included an engagement strategy to ensure
robust, multi-cultural stakeholder involvement to support equitable implementation. The Port’s Central
Procurement Office developed contracts and subsequent amendments. The Port’s Legal department
was engaged to provide guidance on regulatory and legal requirements. Finally, External Relations and
the Office of Equity, Diversity, and Inclusion, provide project management and stakeholder outreach. 
In 2017, the Port established the Airport Community Ecology (ACE) Fund, allocating $1 million of
environmental benefits to airport communities who incur airport noise and pollution. The ACE Fund
transitioned to the ACE Small Matching Grants Program, allowing non-profits to apply for $10,000 twice
annually for public improvement projects. As the ACE Program concluded, Port Commission approved
the South King County Fund (SKCF). On November 27, 2018, through Motion 2018-14, an initial amount
of $750,000 was authorized, as part of a larger budget of $10 million to be used between 2019 and
2023. The SKCF program provides resources and support for Sea-Tac International Airport (SEA) area
communities specifically benefiting South King County nonprofit organizations that support communities
of color and historically marginalized communities through environmental sustainability, small business
capacity building, and economic recovery strategies. Uses for the SKCF may include support for
addressing airport noise and for other projects that support environmental health and enhance
sustainability. 
SKCCIF is permitted under RCW 53.08.245 and 35.21.278: 
RCW 53.08.245 Economic development programs authorized – job training and education 
“It shall be in the public purpose for all port distracts to engage in economic development programs. In
addition, port districts may contract with nonprofit corporations and private and public entities that
provide training systems…and promote workforce diversity in furtherance of this and other acts relating
to economic development.”
RCW 35.21.278 Contracts with community service organizations for public improvements
“Without regard to competitive bidding laws for public works, a county, city, town, school district,
metropolitan park district, park and recreation district, port district, or park and recreation service area
may contract with a chamber of commerce, a service organization, a community, youth, or athletic
association, or other similar association located and providing service in the immediate neighborhood,
for drawing design plans, making improvements to a park, school playground, public square, or port
habitat site, installing equipment or artworks, or providing maintenance services for a facility or facilities
as a community or neighborhood project, or environmental stewardship project, and may reimburse the
contracting association its expense.”
Participating organizations do not receive Port funds once the contract is signed, rather they are
reimbursed after expenses are incurred and an invoice is submitted to the Port for review and approval.
The review process evaluates whether the reimbursement request meets contract deliverables. After it
is determined eligible for reimbursement, the project manager approves the invoice for payment.
Appendix B provides a listing of environmental and economic recovery recipients, contract values, and
the amounts reimbursed for the 12-month period ending December 31, 2021 and the 6-month period
ending June 30, 2022. 
On August 24, 2022 (outside the scope of this audit), the Port announced 12 organizations surrounding
the SEA that will each receive $250,000 from the SKCCIF. This funding supports economic recovery in 
communities hit hardest by COVID-19, through education and job search assistance, skills-based
learning, pre-apprenticeship programs in Port-related industries, habitiat restoration and green job
programs. 

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          South King County Community Impact Fund
Audit Scope and Methodology 
We conducted this engagement in accordance with Generally Accepted Government Auditing Standards 
and the International Standards for the Professional Practice of Internal Auditing. Those standards
require that we plan and conduct an engagement to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our engagement objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and conclusions based on our
engagement objectives. 
The period audited was January 2021 through June 2022 and included the following procedures: 
Internal Controls 
• Verified procedural documents existed and determined whether internal controls had been
identified. 
• Interviewed key personnel, including the Program Manager of Community Investments and the
Senior Program Manager of Community Engagement.
• Obtained a listing of the grant recipients, contract values, contact information, and amount
funded as of June 30, 2022. 
• Tested 100 percent of reimbursement requests to determine if they were reviewed and approved
prior to payment.
• Reviewed the following Revised Code of Washington requirements: 
53.08.245 Economic development programs authorized - job training and education 
35.21.278 Contracts with community service organizations for public improvements 
Compliance with Contractual Requirements / Other 
• Determined whether mid-year and annual “check-ins” were performed and documented, by
validating that a report was provided by the organization that details progress on program
deliverables. 
• Obtained and reviewed contracts. 
• Compared reimbursement requests and supporting documentation to contract requirements, to 
determine whether it was:
1) Allowed by the contract.
2) Within the threshold allowed by the contract.
3) Accompanied with a receipt, when required.
4) Submitted using an expense reimbursement form.
Site Visit 
• Toured the site and met with leaders of Crystal Springs Park (Congolese Basketball Association)
and Hill Top Park (Partners in Employment).




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          South King County Community Impact Fund
Schedule of Findings and Recommendations 
1) Rating: Medium 
Approvals were not always documented, expense reimbursements were not always supported
with receipts, and expenses sometimes exceeded thresholds allowable by the contract.
Although the financial impact is relatively small, these exceptions could be considered noncompliance
with contract terms. 
About twenty-five (25) percent, or 25 of 99 invoices did not have a documented approval. However,
management asserted that approvals were most likely verbal and just not documented. A listing of
expenses that exceeded thresholds are provided in Appendix C. 
Growth of the SKCCIF has steadily occurred over the last three years and continues to grow. Most
recently, on August 24, 2022, 12 additional recipients will each receive $250,000, for a combined $3
million. 
As the program evolves, modifications and adjustments are a natural way to improve how projects are
executed and administered. During our audit, as test results were reviewed with management, we 
brainstormed ideas to improve the program. A consistent theme that surfaced was more flexibility with
contract language. 
While observing RCW requirements is essential, opportunities were identified that, if implemented,
would reducing the amount of time needed for project oversight including the reimbursement process.
These suggestions are especially important for grass roots organizations, who often have limited
resources. The ideas identified in this audit do not suggest that contracts were written incorrectly, rather,
they are offered as proposal to improve efficiency and to make the program more scalable, both with
our external stakeholders and with  Port staff. T he following suggestions  are provided under
Recommendations below:
Recommendations: 
Monthly reports: These reports are due on the 15th of every month. At a minimum, the report is required
to include percent of budget expended, work being performed by time and expense, and issues that
may impact the timing and total price of the work. 
Program managers have frequent communication with leaders of these organizations including monthly
site visits or virtual meetings. Therefore, the need for these additional reports may not be necessary.
Six (6) and Final report: A report is due within six months of contract execution and a final report is
required prior to contract expiration. 
RCW 53.08.245 only requires an annual report, and RCW 35.21.278 does not require any report.
Accordingly, only an annual report may be sufficient. 
Broader contract language: Contractual agreements include an attachment (see Appendix D) that
defines the category and a description of the expense. Based on feedback from Port management, the
granularity of contract language, impacts efficiencies. Considerable time and effort are spent on
communications between Port staff and external recipients so that expenses align to contractual
language. In some instances, contract amendments are drafted so that expenses become eligible. 

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          South King County Community Impact Fund 
Internal Audit understand the importance of establishing deliverables so that payments can be initiated.
However, broadening the contract requirements so that they are less rigid, will reduce time, effort, and
resources focused on contract compliance. 
Management Response/Action Plan: 
External Relations and Office of Diversity, Equity and Inclusion staff agrees with the audit report findings
and will work to implement stronger managerial controls. Staff have implemented a procedure to address
approvals not always being documented. The executive assistant will attach the approval email from the
project managers to each payment submission request. 
Monthly reports and 6th month reports are currently only being requested of Economic Recovery fund
recipients. This reporting practice measures progress towards milestones and goals. Program staff is
committed to working with partners to ensure milestone data is captured as efficiently and effectively as
possible. 
Implementing broader contract language is fully supported by both External Relations and the Office of
Diversity, Equity and Inclusion. We will work diligently and in partnership with the Central Procurement
Office to ensure whenever possible broader language is used which impacts Port efficiencies internally
across multiple departments, and with our community partners. The authority to execute contracts with
broader language exists with CPO, and their Service Agreements team who would need to authorize
the new simplified contract language.

DUE DATE: 6/30/2023 










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          South King County Community Impact Fund

Appendix A: Risk Ratings 
Findings identified during the audit are assigned a risk rating, as outlined in the table below. Only one
of the criteria needs to be met for a finding to be rated High, Medium, or Low. Findings rated Low will be
evaluated and may or may not be reflected in the final report.
Financial      Internal                                               Commission/
Rating                                   Compliance      Public 
Stewardship  Controls                                         Management 
High probability
Non-compliance
Missing or not                       for external audit   Requires
with Laws, Port
High       Significant     followed                          issues and / or     immediate
Policies, 
negative public     attention 
Contracts 
perception 
Partial              Potential for
Partial controls 
compliance with   external audit
Requires
Medium   Moderate                  Laws, Port       issues and / or
Not functioning                                          attention 
Policies             negative public
effectively 
Contracts          perception 
Functioning as
Low probability
intended but     Mostly complies                       Does not
for external audit
could be        with Laws, Port                       require
Low      Minimal                                   issues and/or
enhanced to     Policies,                            immediate
negative public
improve        Contracts                           attention 
perception 
efficiency 










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          South King County Community Impact Fund

Appendix B: Contract Values and Reimbursements 
Note: 2022 are reimbursements through June 30, 2022. 

Table I. Environmental
Organization                                           Contract Value           2021           2022
Bridging Cultural Gaps                                              $19,974         $14,050               -
Tilth                                                                         14,800             5,535             9,265
Friends of Normandy Park                                        11,163           4,867           4,474
Federal Way Korean American Association                         20,000              -                -
Multicultural Self-Sufficiency Movement                                 9,000               -                  -
Puget Soundkeeper Alliance                                        10,902              -                -
Bhutanese Community Resource Center                           13,488           6,500             -
Summer Search (Congolese Basketball Team)                      19,000             -             3,075
Summer Search (Expanding Environmental Justice)                  19,990              -                -
Partner in Employment                                             19,977              -            19,977
$158,294        $30,952        $36,791


Table II. Economic Recovery
Organization                                           Contract Value           2021           2022
African Chamber of Commerce PNW                          $100,000       $21,539        $70,128
African Community Housing and Development                      99,903          61,000          38,903
Asian Counseling and Referral Service                               70,000          35,500          28,250
Business Ending Slavery and Trafficking (BEST)                    100,000          61,800          15,162
Cares of Washington                                            91,160          77,387          13,773
Chief Seattle Club                                                   100,000           57,500           42,500
El Centro de la Raza                                                99,985          75,000          24,985
Highline College Foundation                                         90,839            5,750          43,250
Partner in Employment                                           100,000          79,375          20,625
Washington Maritime Blue                                         99,995          99,995              -
$951,882       $574,845       $297,576






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Appendix C: Exceptions
Organization                    Contract Description                         Reimbursement Amount not allowed Description of Reimbursement
Summer Search                  Refreshments $31.25 / event X 32 events = $1,000     $       97.04      $         65.79     13 Coins - Brainstorming Dinner
Refreshments $31.25 / event X 32 events = $1,000            135.84                104.59      Buffalo Wild Wings - Park Cleaning Event
Refreshments $31.25 / event X 32 events = $1,000             38.04                6.79    McDonalds - Park Cleaning Event
Refreshments $31.25 / event X 32 events = $1,000            211.39                173.35      Taste of Congo - Park Cleaning Event
Refreshments $31.25 / event X 32 events = $1,000             40.24                8.99    Jack in the Box - Park Cleaning Event
Refreshments $31.25 / event X 32 events = $1,000             37.89                6.64    Target - Refreshments
Refreshments $31.25 / event X 32 events = $1,000             94.69                63.44     Taste of Congo - Park Cleaning Event
Partner in Employment              Crew Lead $25 * 360 hours = $9,000                    9,352.50                 352.50      Staff / Contractor Time
Youth Stipend $1,000 * 5 youths = $5,000                 9,826.00                4,826.00       Volunteer Support
Class Roster of Enrolled Participants in RiVET,
Highline College Foundation           AutoCAD or Civil3D courses ($19,530)                  32,000.00                12,470.00        Class Roster
Friends of Normandy Park            2 weed wrenches X $10.25 = $20.50                       79.24                58.74     Weed Wrench
20 gloves X $1 = $20                                187.24                167.24      Gardening Gloves
Refreshments $35 / event X $6 events - $210                 39.53                4.53    Starbucks Coffee
Refreshments $35 / event X $6 events - $210                 39.53                4.53    Starbucks Coffee
Bhutanese Community Resource Center   1 Hand Washing Station X $70 = $70                      79.18                9.18    Handwashing Station
25 boxes garbage bags X $20 = $500                     523.76                23.76     Garbage Bags
25 compost bins X $46 = $1,150                       1,277.10                 127.10      Compost Bins
Staff Training / Volunteer Coordination $30 X 260 hours
Tilth
= $7,800                                       7,923.70                 123.70      Staff Support
Guest Instructor Stipend $250 X 4 speakers = $1,000          1,700.00                 700.00      Guest Instructors
Project Supplies $3,000                             3,526.30                 526.30      Project Supplies
Bridging Cultural Gaps              Plants $500                                     1,800.00                1,300.00       Plants










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Appendix D: Contract Example 















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